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Submission to East Devon Local Plan

1. Listing of Knowle, Station Road, Sidmouth: 1951

Knowle, described at e. below, appears to have been listed in 1951 and to have lost its listing since then. Its owner, East Devon District Council is considering selling it for redevelopment. Certainty about its protected status and clarification of any confusion is urgently required.

The two buildings named Knowle in Sidmouth are located on two sites, Station Road and Harcombe. There is no concern about Knowle Harcombe (a.).

The buildings/features associated with the two sites are:

a. HARCOMBE C17 country house rehandled ca 1840-50 near the hamlet in Sidbury parish to the north-east of Sidmouth. Listed 12 Nov 1973; English Heritage Building ID no. 402406

b. STATION ROAD Grotto in the garden of Knowle Grange. Listed 1951; no. 402406

c. STATION ROAD Summerhouse in the grounds of Knowle, Sidmouth Urban District Offices. Listed 12 Nov 1973; no. 1228078

d. STATION ROAD Lodge at the entrance to the drive leading to Sidmouth Urban District Offices. Listed: not stated, probably 12 Nov 1973; no. 1227917

e. STATION ROAD Knowle, formerly Knowle Cottage (1810-1885), Knowle Hotel (1885-1950), Sidmouth Urban District Offices (1964-1974). East Devon District Council Offices (from 1974). Finished 1810 as large cottage ornée for Lord le Despenser. Listed 1951. No longer listed.

(note 1)

Knowle Station Road (e.) is recorded (as Knowle Hotel) as having been scheduled on the statutory list of the Ministry of Housing and Local Government in 1951 as being of outstanding historical and architectural interest. (See attached copies from Sidmouth Observer 9 July 1952)Other hotels/inns were similarly listed. All the hotels/inns in the Sidmouth Observer’s record appear on the current English Heritage list; Knowle does not.

(note 2)

Note 1: In the British Listed Buildings and English Heritage lists, the address [Knowle Dr, Sidmouth, Devon], postcode [EX10 8HL] and OS Coordinates [312042, 87954] for Knowle House Harcombe’s had been recorded as those of Knowle, Station Road. This was conveyed to English Heritage on 16th May 2012 and these details were subsequently corrected.

It seems that Knowle Station Road had become confused with Knowle House, Harcombe. If this is correct, there may not have been an intention to remove Knowle Station Road from the 1951 schedule.

Note 2: If the list of hotels in the article of 9 July 1952 is compared to that on the British Listed Buildings website, we notice the following:

  • All 14 hotels and inns except Knowle are listed in the 2012 list. Six were recorded as having been listed in 1951, the remainder in 1973. Knowle House Harcombe was listed in 1973.
  • Duffert’s Commercial Hotel is on the site now occupied by the Black Horse Hotel on 41 Fore St, Sidmouth. (source: Sidmouth Museum). It was listed in Nov 1973 and has the list entry no. 1288890.
  • This means that all the hotels and inns on the Sidmouth Observer list of July 1952 except Knowle Hotel are on the present English Heritage list.

These questions arise:

  1. Did the 1951 Ministry of Housing list become the present English Heritage list?
  2. Was the Sidmouth Observer correct in recording Knowle (e. above) as on the statutory list of 1951?
  3. Why is Knowle (e. above) no longer thus protected?
  4. Some buildings on the Sidmouth Observer list are recorded in the present English Heritage list as having been listed from 1973 and others from 1951. Why is this?
  5. Did Knowle Station Road ‘disappear’ from the 1951 list because Knowle Harcombe was added and given the incorrect co-ordinates?(Submitted to English Heritage 31 st May 2012)

2. Granting Knowle grounds Area TPO: 1956

In 1956, a Tree Preservation Order relating to Manor Park and Knowle Hotel was countersigned by the Assistant Secretary to the Minister of Housing and Local Government. The documentation specifically refers to the grounds as ‘parkland’.

The District Council has made recent references to this Order:

What impact will any future development at Knowle have on the many fine trees on the site? Are the trees covered by a Tree Protection Order (TPO)?

Trees are obviously a material consideration on this site and we will deal with them as sensitively as we can through the planning process. The grounds of Knowle are the subject of an Area TPO made in 1956. The effect of this order is to protect all trees that were growing in 1956 and therefore covers any tree over 55 years old. The TPO prevents trees being removed before any detailed planning consent and protects those trees shown as retained on the approved plans, both during and after construction. The potential to retain any tree is determined by the health and condition of the individual tree and whether it has significant amenity, historic or conservation value. The Council’s own policies and the criteria set down in BS 5837:2012 (Trees in relation to design, demolition and construction – Recommendations) ensure that all trees will be taken into account and considered on their merits.

Page last updated on 7 June 2012.

However, there are concerns that this TPO will not provide adequate protection for mature trees:

  1. There are contradictions in official maps of Knowle as to what signifies ‘parkland’ or ‘open space’. It is not clear whether the most recently adopted planning policy document supersedes an earlier document; or whether a planning application, if approved, overrules any TPOs.The 1956 Area TPO map A2 designates a clear boundary for the parkland at Knowle; it is within this area that all trees now 55 years old would receive protection. The ‘designated recreation parkland’ of the Sidmouth Urban Inset Map 58 of Knowle from 1996 seems to confirm this boundary. And yet, the Sidmouth Inset Map 45 of the 2006 and 2011 drafts of the Local Plan define a different boundary which excludes the ‘recreation area’ of the lawn in front of the present West Wing.Independent surveys have identified 16 mature trees including beech, Monterey pine, yews and hawthorn which lie in this area marked for housing development at Knowle in the 2011 Inset Map; that is, the proposed development line down to the depot offices would necessitate the felling of trees protected by the 1956 Order.
  2. There are concerns that the District Council will not respect the integrity of TPOs. The case of ‘Cedar Shade’ from 2008 has thrown into doubt undertakings made by Officers.Sidmouth Town Council raised concerns in the Minutes of its Planning Committee at point 08:9/P15.5:On 16th May, the Clerk wrote to the District Council regarding the above application expressing concern regarding the behaviour of the Property Developers at Cedar Shade in respect of the trees. The Clerk reported that a reply was still awaited. the development of new homes at ‘Cedar Shade’ in April 2008 it appears that the District Council gave permission for the TPO to be:… suspended in order to allow redevelopment to take placeThe council decided that all the trees that were in the developer’s way were either “over-mature” or were diseased or more dangerous (and couldn’t be made safe?) What a convenient coincidence!! The County Highway Authority had recommended refusal of the planning application. That recommendation was rejected by EDDC. (Letter to Sidmouth Herald: 17th June 2008), there are fears that no TPOs are safe in the District:This must not be allowed to become a most dangerous precedent to wholesale wrecking of Sidmouth’s heritage.

3. Knowle declared as ‘Public Open Space’: 1973

Documents in the public domain clearly contradict District Council declarations that there is no Public Right of Way through the Knowle grounds:

  1. A cutting from the Sidmouth Herald of 28th July 1973 refers to the decision of Sidmouth UDC to make the order to dedicate the Knowle for ever as a ‘public open space’ before it became the HQ of the new EDDC authority on April 1st 1974.
  2. SUDC Minutes of 1973 make recommendations, in the Clerk’s Finance Report (headed 24th July 1973 and signed 2nd October 1973). The entry clearly states that the public have established access to the grounds prior to 1973 and recommends that they become a public open space under Section 164 of the Public Health Act 1875 as public open spaces. Of particular importance is the sentence: “It will moreover be recalled that a principal reason for the acquisition of Knowle was to preserve the gardens and field as an amenity for the district”.

Devon County Councillor Stuart Hughes, with Cabinet responsibility for Highways, wrote to the District Council CEO in May 2012, ‘requesting that the District Council dedicate footpaths within Knowle grounds as PROW’:

Dear Mark

Having taken advice from our PROW team at County Hall I am writing to request that the District Council dedicate footpaths within the Knowle grounds as public rights of way, through dedication or creation agreements as the landowners with the County Council under section 25 of the Highways Act 1980. They (the footpaths) would then be recorded on the Definitive Map as public rights of way.

As I understand it this can be done through the solicitors in East Devon’s legal department contacting Devon’s PROW section who can advise on the procedures.

As you are aware with the newspaper articles on the possibility of EDDC moving there is a vast amount of concern regarding this issue within the town and it is an easier procedure to record public rights of way than going through the investigation of evidence to add them to the Definitive Map by Modification Order as they are currently not recorded as rights of way, although there have already been queries from members of the public about how to do that.

I now look forward to hearing from you

Best regards

Stuart Hughes CC

As already stated, there are contradictions in official maps of Knowle as to what signifies ‘parkland’ or ‘open space’. Versions of the Sidmouth Inset Map prior to the current 2011 version clearly show the grounds of the Knowle as ‘protected’, designating the whole of the undeveloped part of the Knowle site as ‘Land of Local Amenity Importance’.

Furthermore, District Council Policy EN1 relates to land which is within or adjacent the AONB – and Knowle is immediately adjacent to the AONB. And as such, Policy EN1 states that development will only be permitted within or adjacent the AONB where the proposal conserves or enhances the landscape character of the area and respects traditional built form

Proposals under the draft Local Plan to limit Public Rights of Way and to build upwards of 50 dwellings not only fail to meet these criteria but fail to clarify why there should be any change in the boundary designation, which should remain as it was prior to the latest revision.


These documents throw into serious doubt the legitimacy and feasibility of the proposed relocation of the District Council from Knowle.

Firstly, relocation threatens to destroy the integrity of the parkland. The stately setting of Knowle – with its combination of magnificent parks, historic trees and palatial proportions – is of considerable importance to the quality and prosperity of Sidmouth.

Secondly, relocation would seriously undermine public confidence in the District Council’s commitment to observing its own stated principles. Many of the proposals relating to Knowle in the draft Local Plan fail to comply either with previous policies or with due process.

Jeremy Woodward
66 Temple St, Sidmouth, EX 10 9BJ
10th June 2012

(Letter from SVA Chair Handel Bennett: 18th April 2008)

A suspended TPO implies that it is temporary action, and will be restored. In this case it seems to have been a convenient way of allowing the destruction of healthy trees, of no danger to anyone, except the financial considerations of the developer. It suggests the re-developer must have intended from the start to destroy these trees, otherwise he would have planned to include them within his planning application.

(Letter from SVA Chair Handel Bennett: 18th April 2008)

Members of the public as well as the Sid Vale Association have expressed doubt about the planning process:

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EDDC – Next Stages in the New Local Plan

On the 8th May the Development Management Committee of the Council considered a revised version of the new Local Plan. The Committee also agreed to consultation over a four week period on maps for the seven main towns of East Devon including Sidmouth

Download the revised version of the new Local Plan (5639KB-09 May 2012 ).
Download the Sidmouth Plan (255KB – 10 May 2012 )
Visit the EDDC site for full details of the plan for the whole of East Devon.

EDDC would welcome comments on these maps and related policies. Comments must be received by 12 noon on 11 June 2012.  We will take comments and further plan amendments back to Council in July 2012.

Please email comments to: or
By post to: Planning Policy , East Devon District Council, Knowle, Sidmouth EX10 8HL